How to Use the Commerce Country Chart (Step-by-Step)
Learn how to read Supplement No. 1 to Part 738 of the EAR — the Commerce Country Chart — to determine whether a license is required for your export destination.
Introduction
The Commerce Country Chart (Supplement No. 1 to Part 738 of the Export Administration Regulations) is the primary tool exporters use to determine whether a license is required from BIS before exporting a controlled item to a specific destination. It cross-references Reasons for Control (column headers) against destination countries (rows).
This guide walks through the chart step-by-step, explains how it interacts with ECCNs and license exceptions, and highlights common pitfalls.
Prerequisites: What You Need Before Using the Chart
Before you can use the Commerce Country Chart, you must have already completed two prior steps:
- Determined your item's ECCN — The five-character alphanumeric code from the Commerce Control List (CCL). If your item is classified as EAR99, the Country Chart does not apply (EAR99 items generally do not require a license unless end-use or end-user concerns apply under Part 744).
- Identified the applicable Reasons for Control — Every ECCN entry on the CCL lists its Reasons for Control in the "License Requirements" section. Common reasons include NS (National Security), MT (Missile Technology), NP (Nuclear Nonproliferation), CB (Chemical & Biological Weapons), AT (Anti-Terrorism), RS (Regional Stability), CC (Crime Control), and FC (Firearms Convention).
The Chart's Structure
The Commerce Country Chart is organized as a grid:
- Rows = Countries (listed alphabetically)
- Columns = Reason for Control codes, subdivided into column numbers (e.g., NS Column 1, NS Column 2, AT Column 1, AT Column 2)
Each cell contains either an "X" or is blank:
- X = A license IS required for that combination of country + reason for control column
- Blank = A license is NOT required for that specific reason (though other reasons may still trigger a requirement)
Column Numbers Explained
Many control reasons have multiple columns (e.g., NS Column 1 and NS Column 2). The specific column that applies to your transaction is identified in the ECCN's "License Requirements" section. For example, an ECCN entry might state:
> Reason for Control: NS applies to entire entry. NS Column 1.
This tells you to look at the NS Column 1 for your destination country.
Step-by-Step Process
Step 1: Find the Reasons for Control in Your ECCN
Open the CCL entry for your ECCN. Under "License Requirements," find the listed Reasons for Control and their applicable column numbers. An ECCN may have multiple reasons — you must check ALL of them.
Example: ECCN 4A003 (Digital Computers)
- Reason for Control: NS applies to entire entry. NS Column 1.
- Reason for Control: AT applies to entire entry. AT Column 1.
Step 2: Locate Your Destination Country
Find your destination country in the alphabetical rows of the chart. Use the country's official name as recognized by the U.S. government (e.g., "Korea, South" not "South Korea"; "China, People's Republic of" not "China").
Step 3: Check Each Applicable Column
For each Reason for Control column identified in Step 1, check whether an "X" appears in that column for your destination country.
If ANY column shows an "X" — a license is required (unless a license exception applies).
If ALL applicable columns are blank — no license is required for those control reasons (but you must still check for other restrictions under Parts 744 and 746).
Step 4: Check for License Exceptions
If the chart indicates a license is required, check whether a license exception can authorize the export. The ECCN entry's "License Exceptions" section lists which exceptions are eligible. See our License Exceptions guide for details.
Worked Example
Scenario: You want to export a digital computer (ECCN 4A003) to India.
- ECCN 4A003 Reasons for Control: NS Column 1, AT Column 1
- Find India on the chart
- Check NS Column 1 for India: X (license required for NS)
- Check AT Column 1 for India: Blank (no requirement for AT alone)
- Result: Because NS Column 1 has an X, a license IS required — unless a license exception (such as STA for India, which is in Country Group A:5) applies.
Country Groups and Their Relationship to the Chart
The EAR also uses Country Groups (defined in Supplement No. 1 to Part 740) that categorize countries by their participation in multilateral export control regimes:
| Group | Basis | Significance |
|---|---|---|
| A:1 | Wassenaar Arrangement | Dual-use arms export controls |
| A:2 | MTCR | Missile technology controls |
| A:3 | Australia Group | Chemical/biological weapons |
| A:4 | Nuclear Suppliers Group | Nuclear nonproliferation |
| A:5 | Eligible for STA (¶c)(1) | Broad license exception eligibility |
| A:6 | Eligible for STA (¶c)(2) | Narrower STA eligibility |
| B | General destinations | Wide range of countries |
| D:1 | National Security concerns | More restrictive NS controls |
| D:2 | Nuclear concerns | More restrictive NP controls |
| D:3 | Chemical/Biological concerns | More restrictive CB controls |
| D:4 | Missile Technology concerns | More restrictive MT controls |
| D:5 | U.S. Arms Embargoed | Comprehensive restrictions |
| E:1 | State Sponsors of Terrorism | Most restrictive controls |
| E:2 | Unilateral embargo (specific) | Country-specific prohibitions |
Countries in Group D and E generally have "X" marks in most or all Country Chart columns. Countries in Group A (especially A:5) tend to have fewer restrictions and broader license exception eligibility.
Common Pitfalls
Pitfall 1: Stopping After One "Blank"
If your ECCN has multiple Reasons for Control, you must check ALL applicable columns. A blank in one column does not mean you are clear — another column may still show an "X."
Pitfall 2: Ignoring Part 744 and 746
The Commerce Country Chart only addresses Part 742 license requirements. Separate restrictions may apply under:
- Part 744 — End-use and end-user controls (Entity List, Military End-Use, etc.)
- Part 746 — Embargoes and other special controls (Russia, Belarus, Cuba, Iran, North Korea, Syria)
A "blank" on the Country Chart does NOT guarantee you can export without a license if Part 744 or 746 restrictions apply.
Pitfall 3: Using the Wrong Country Name
The chart uses official U.S. government country names. "Taiwan" is listed as "Taiwan" but some older references used "China (Taiwan)." Always verify you are looking at the correct row.
Pitfall 4: Confusing Country Groups with the Country Chart
Country Groups (Part 740, Supplement No. 1) and the Commerce Country Chart (Part 738, Supplement No. 1) are different tools. Country Groups determine eligibility for license exceptions. The Country Chart determines whether a license is needed in the first place.
Where to Access the Chart
- Official source: 15 CFR Part 738, Supplement No. 1 via eCFR
- Interactive version: BIS Interactive Commerce Country Chart (allows country-specific lookups)
- ECCN Finder: Use our ECCN database to find the Reasons for Control for any ECCN, then cross-reference with the chart
Conclusion
The Commerce Country Chart is the central decision point in the EAR licensing analysis. Mastering it requires understanding three things: your ECCN's Reasons for Control, the chart's column structure, and the limitations of the chart (it does not cover Part 744/746 restrictions). Always use the chart as one step in a comprehensive compliance review, not as the final word.
For additional context on classification, see our How to Find Your ECCN guide. For next steps after determining a license is required, see our License Exceptions guide.